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Comment 11 for Public Workshop on Cap-and-Trade Regulation Amendments: Post-2020 Cap Setting and Allowance Allocation (caps-allocation-ws) - 1st Workshop.
First Name: Bruce
Last Name: Ray
Email Address: bruce.ray@jm.com
Affiliation: Johns Manville
Subject: Comments of Johns Manville on CARB Post-2020 cap/allocation workshop on March 29, 2016
Comment:
Johns Manville (JM) operates a fiber glass insulation manufacturing plant in Willows in Glenn County about an hour north of Sacramento. The JM Willows plant is designated ARB ID No. 104122 and falls within NAICS Code 327993 (mineral wool). We attended the March 29, 2016 workshop on “Cap-and-Trade Regulation Post-2020 Emissions Caps and Allowance Allocation” and offer the following comments: • The JM Willows plant participates in the current cap and trade program. At the end of the current program in 2020 we expect to be in allowance surplus. At the workshop I requested that staff confirm that JM can carry over our pre-2020 surplus into the post-2020 program for use in meeting our post-2020 compliance/surrender obligations. This was in fact confirmed by staff response and will guide our compliance strategy going forward. • Clarification is needed on whether net electricity will be accounted for at the state-wide emission factor or at the individual provider’s portfolio’s numbers. It should be noted that those latter numbers may not be available in time for submittal to CITTS. CARB should also clarify if the statewide numbers will be adjusted year over year. • For strategic planning purposes, the numbers CARB will use as electricity emission factors should be published well in advance. • CARB should clarify how including direct allocation for purchased electricity will affect the current mandatory participation threshold of 25,000 MT CO2e per year as well as the mandatory reporting threshold of 10,000 MT CO2e per year. At the March 29, 2016 workshop, staff announced that there will soon be scheduled a workshop on leakage risk. Industrial allowance allocations and leakage are closely related. Accordingly, we look forward to the leakage workshop and will be submitting additional comments on both leakage and industrial allocations. Thank you, Bruce D. Ray, Director of Governmental and Regulatory Affairs, Associate General Counsel Johns Manville 717 17th Street (80202) | Denver, Colorado 80217-5108 P: 303 810 9723
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Date and Time Comment Was Submitted: 2016-04-15 16:08:53
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